1
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
Title:
Cooperative
Agreements
and
Superfund
Contracts
for
Superfund
Response
Actions
(
OMB
Control
number
2050­
0179;
EPA
ICR
No.
1487.07).

This
is
a
request
for
a
renewal
of
an
existing
Information
Collection
Request
(
ICR)
due
to
expire
on
September
30,
2001.
The
title
of
this
submission
is:
"
Cooperative
Agreements
and
Superfund
Contracts
for
Superfund
Response
Actions."
This
ICR
authorizes
the
collection
of
information
under
EPA's
Superfund
Rule
(
40
CFR
35
Subpart
O)
that
establishes
the
administrative
requirements
for
CERCLA­
funded
cooperative
agreements
for
State,
political
subdivisions,
and
Federally
recognized
Indian
tribal
government
response
actions.
The
regulation
includes
only
those
provisions
as
mandated
by
CERCLA,
required
by
OMB
circulars,
or
added
by
EPA
to
ensure
sound
and
effective
financial
assistance
management.
The
information
required
by
this
regulation
will
be
used
by
EPA
award
officials
to
make
assistance
awards,
to
approve
payments,
and
to
verify
that
the
recipients,
in
using
Federal
funds
appropriately,
comply
with
OMB
Circulars
and
meet
the
cost
recovery
provisions
of
CERCLA.

2.
Need
for/
Use
of
the
Collection
2(
a).
Need
 
This
ICR
is
necessary
due
to
the
information
collection
and
reporting
requirements
in
the
Superfund
rule
(
40
CFR
Part
35
Subpart
O)
entitled,
"
Cooperative
Agreements
and
Superfund
Contracts
for
Superfund
Response
Actions."
Due
to
the
statutory
cost
recovery
requirements
in
CERCLA
and
the
need
to
carefully
track
all
costs,
Superfund
recipients
must
comply
with
administrative
requirements
sufficient
to
meet
these
provisions
of
the
law.
The
regulation
sets
forth
the
pre­
award,
post­
award,
and
after­
the­
cooperative
agreement
requirements
which
are
conditions
for
receiving/
managing
a
Superfund
cooperative
agreement
or
a
Superfund
State
Contract
(
SSC).
This
information
is
needed
by
EPA
project
officers,
grant
specialists,
and
finance
officials
to
manage/
oversee
the
funding
activities
and
cleanup
activities
at
Superfund
sites.
EPA
also
uses
the
information
to
update
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Information
System
(
CERCLIS)
which
tracks
progress
made
at
Superfund
sites.

2(
b).
Use
 
The
pre­
award
information
is
used
to
qualify
cooperative
agreement
applicants
and
award
cooperative
agreements.
The
post­
award
information
is
used
to
meet
the
statutory
and
regulatory
requirements
and
monitor
recipient
performance.
The
closeout
information
is
used
to
meet
reporting
and
record
keeping
requirements
necessary
for
cost
recovery
purposes
and
for
closing
out
awards.
The
information
is
necessary
to
ensure
minimum
fiscal
control
and
accountability
for
Hazardous
Substances
Superfund
money
to
deter
waste,
fraud,
and
abuse.
2
The
Superfund
rule
also
supplements
EPA's
general
assistance
regulation,
40
CFR
Part
31,
the
Uniform
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments.
Part
31,
which
implements
the
requirements
of
OMB
Circular
A­
102,
became
effective
for
awards
made
on
or
after
October
1,
1988.
The
Part
31
rule
(
common
rule)
established
uniformity
among
Federal
agencies
that
award
Federal
grants
and
cooperative
agreements
to
States,
political
subdivisions
thereof,
and
Federally­
recognized
Indian
Tribal
Governments.
Many
of
the
information
collection
requirements
for
Superfund
cooperative
agreements
were
approved
under
the
OMB
Paperwork
Clearance
#
2030­
0020
associated
with
40
CFR
Part
31
prior
to
this
ICR.
See
Table
1
below.

Table
1
­
Burdens
covered
under
other
ICRs
Task/
Burden
#
of
ICR
task/
burden
is
imposed
under
SF­
269
(
annually)
2030­
0020
SF­
334
2030­
0020
SF­
424
2030­
0020
SF­
424A
2030­
0020
List
of
Sites
partially
covered
under
HRS
EPA
5700­
48
2030­
0020
EPA
5700­
49
2030­
0020
Anti­
lobbying
certification
0348­
0046
Health
and
safety
plan
partially
covered
under
HRS
Quality
assurance
plan
2030­
0403
Site
description
NCP
Site
specific
statement
of
work
(
SOW)
NCP
Site
specific
community
relations
plan
NCP
Schedule
of
deliverables
NCP
Quarterly
Progress
reports
Part
31
Property
inventory
reports
Part
31
Financial
reports
Part
31
Due
to
statutory
cost
recovery
requirements,
and
the
need
to
carefully
track
costs
by
site
and
activity,
Superfund
recipients
must
comply
with
all
administrative
requirements
to
satisfy
the
provisions
of
the
law.
There
are
additional
requirements
in
the
Superfund
rule,
which
3
supplements
Part
31,
and
are
essential
for
effective
cost
recovery
from
potentially
responsible
parties.
The
following
identifies
the
information
collection
requirements
contained
in
this
regulation:

(
1)
Sections
35.6055(
a)(
2)
and
(
b)(
2)(
I)
and
(
ii);
35.6105(
a)(
2)(
I)(
ii)­(
v),
(
vii);
35.6105(
b);
35.6110(
b)(
2);
35.6120;
35.6145;
35.6155(
a),
(
c);
35.6230(
a),
(
c);
35.6300(
a)(
3);
35.6315(
c);
35.6320;
35.6340(
a),
35.6350'
35.6500;
35.6550(
a)(
ii),
(
b)(
I)(
iii)
and
(
2(
I);
35.6585;
35.6595(
a);
35.6650;
35.6700;
35.6705,
35.6710;
35.6805;
and
35.6815(
a)­(
d),
of
the
Superfund
rule
contain
collection
of
information
requirements.
These
involve:
applications;
certifications
regarding
debarment,
suspension
and
other
responsibility
matters;
procurement
certifications;
antilobbying
certifications;
intergovernmental
reviews;
health
and
safety
plans;
community
relations
plans;
quality
assurance
plans;
accounting
and
financial
records,
property
purchase
cost
comparison
and
user
rate
analysis;
property
procurement
and
disposition,
cost,
price,
or
profit
analysis;
technical
performance
reports;
property
inventory
reports;
procurement
reports;
financial
reports;
records
retention;
records
access;
and
closeout.

All
of
the
above
sections
were
originally
cleared
under
ICR
No.
0938.07
(
OMB
Control
number
2030­
0020)
for
use
through
9/
30/
01.

3.
Non­
duplication,
Consultations,
and
other
Collection
Criteria
3(
a).
Non­
duplication
 
There
is
no
other
known
source
for
this
information.

3(
b).
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
The
first
notification
of
this
request
for
renewal
of
an
existing
Information
Collection
Request
(
ICR)
was
published
in
the
Federal
Register
on
May
10,
2001
(
copy
attached
 
Table
A).
No
responses
were
received
during
the
sixty
day
comment
period.

3(
c).
Consultations
­
A
panel
of
EPA
regional
staff
members
and
state
environmental
agency
staff
with
extensive
experience
in
managing
and
supervising
Superfund
cooperative
agreements
were
consulted
in
detail
during
the
process
of
producing
this
information
collection.
These
consultations
consisted
of
several
conference
calls
where
potential
and
actual
burdens
imposed
on
states
and
political
subdivisions
by
the
Superfund
rule
were
discussed.
The
experience
of
the
staff
involved
allowed
for
a
more
detailed
burden
calculation.

3(
d).
Effects
of
Less
Frequent
Collection
 
There
is
no
fixed
schedule
for
the
collection
of
this
information.
It
is
required
on
an
"
as
needed"
basis
as
stated
in
the
final
Superfund
rule
(
40
CFR
35
Subpart
O)
entitled
"
Cooperative
Agreements
and
Superfund
Contracts
for
Superfund
Response
Actions."

3(
e).
General
Guidelines
 
The
information
collection
is
consistent
with
the
guidelines
set
forth
in
5
CFR
1320.6
of
the
Paperwork
Reduction
Act
Guidelines.
4
3(
f).
Confidentiality
 
No
confidentiality
is
provided
and
no
sensitive
information
is
collected
under
this
ICR.

3(
g).
Sensitive
Questions
 
Sensitive
questions
are
not
associated
with
the
information
collection
activities
performed
under
the
Superfund
rule.

4.
Respondents
and
Information
Requested
4(
a).
Respondents/
SIC
Codes
 
Respondents
in
this
collection
effort
are
State,
political
subdivision,
and
Federally
recognized
Indian
tribal
governments.
There
are
currently
no
systems
applying
current
technology
that
would
reduce
this
burden.
In
consideration
of
Federalism,
Executive
Order
13132,
reporting
and
record
keeping
is
kept
to
a
minimum.
The
Standard
Industrial
Code
for
all
respondents
is
921190
(
Other
General
Government
Support).

4(
b).
Information
Requested
 
Local
and
Indian
tribal
government
recipients
are
required
to
follow
the
minimum
financial,
property,
procurement,
and
general
administrative
procedures
necessary
to
recover
funds
for
the
Hazardous
Substance
Superfund.
State
recipients
are
also
required
to
adhere
to
these
standards
due
to
cost
recovery.
Recipients
may
choose
to
follow
their
own
procurement
procedures
by
certifying
that
their
procedures
meet
the
intent
of
the
regulatory
requirements.
Data
respondents
are
typically
required
to
submit
includes,
but
is
not
limited
to:
financial
statements,
bills,
receipts,
reports,
etc.

5.
The
Information
Collected
 
Agency
Activities,
Collection,
Methodology
and
Information
Management
5(
a).
Agency
Activities
 
Most
of
the
information
will
be
collected
using
standardized
reports
and
record
keeping
appropriate
to
support
cost
recovery.
The
grants
information
is
entered
into
GICS,
the
Agency's
database
for
tracking
the
status
of
grant/
cooperative
agreement
actions.
The
technical
(
programmatic)
information
is
entered
into
CERCLIS
the
Agency's
database
for
tracking
the
status
of
all
response
activities
at
Superfund
sites,
and
financial
information
is
entered
into
IFMS,
the
Agency's
database
for
tracking
financial
management.

5(
b).
Collection
Methodology
and
Management
 
These
reports
are
reviewed
in
accordance
with
the
requirements
of
40
CFR
Part
35
Subpart
O.
Superfund
recipients
must
retain
records
for
10
years
following
the
submission
of
the
final
Financial
Status
Report,
and
must
retain
those
records
longer
if
an
enforcement
action
is
ongoing.
This
ensures
that
response
action
information
will
be
available
to
support
EPA
litigation
efforts
to
recover
Superfund
costs
from
responsible
parties.
The
Agency
also
conducts
periodic
on­
site
reviews
to
ensure
recipient
compliance
with
applicable
requirements.
5
5(
c).
Small
Entity
Flexibility
 
The
information
requirements
do
not
pertain
to
small
business
or
other
small
entities.

5(
d).
Collection
Schedule
 
The
collection
schedule
for
these
Cooperative
Agreements
and
Superfund
Contracts
is
variable
depending
on
such
factors
as:
Date
of
applications,
magnitude
of
efforts,
and
project
periods,
etc.

6.
Estimating
the
Respondent
Burden
and
Cost
of
Collection
6(
a).
Estimating
the
respondent
burden
­
A
"
unit"
burden
is
the
burden
incurred
by
a
respondent
for
performing
a
Cooperative
Agreement
(
CA)
specific
activity.
States
incur
burdens
under
an
estimated
358
Cooperative
Agreement
and
Superfund
State
Contract
(
SSC)
activities
per
year
for
reporting,
certifications,
schedules,
notifications,
assurances,
and
record
keeping
activities.
The
estimated
burden
is
incurred
by
activities
under
the
following
types
of
CAs/
SSCs
and
other
requirements:

°
Pre­
remedial
Cooperative
Agreements;
°
Remedial
Response
Cooperative
Agreements;
°
Enforcement
Cooperative
Agreements;
°
Removal
Cooperative
Agreements;
°
Core
Program
Cooperative
Agreements;
°
Support
Agency
Cooperative
Agreements;
°
Records
Retention;
°
Superfund
State
Contract;
°
Conclusion
of
the
SSC;
and
°
Consolidated
Funding.

The
estimated
average
burden
associated
with
each
CA/
SSC/
Other
requirement
is
discussed
below
and
summarized
in
Table
2.
6
Table
2
­
State
Burden
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
number
of
respondents
per
Year
(
Full)
Average
number
of
potential
respondents*
(
Amendments)
Total
Burden
(
Hours)
Total
Cost
(
Dollars)

Pre­
remedial
CA
6.8
$
32.46
$
220.78
33
26
283.33
$
9,199.17
Remedial
response
CA
10.84
$
32.46
$
351.87
30
19
393.85
$
12,784.61
Enforcement
CA
43.36
$
32.46
$
1,407.47
1
0
43.36
$
1,407.47
Removal
response
CA
42.36
$
32.46
$
1,375.00
21
1
903.68
$
29,333.33
Core
program
CA
8
$
32.46
$
259.68
22
22
234.67
$
7,617.28
Support
agency
CA
4
$
32.46
$
129.84
45
36
228.00
$
7,400.88
Records
retention
5.6
$
32.46
$
181.44
375
0
2100
$
68,040.00
SSC
20
$
32.46
$
649.20
52
0
1040.00
$
33,758.40
Conclusion
of
SSC
1.5
$
32.46
$
48.69
0
0
0
$
0.00
Consolidated
funding
68
$
32.46
$
2,207.28
2
3
204.00
$
6,621.84
TOTAL
581
107
5430.89
$
176,162.98
TOTAL
NUMBER
OF
RESPONDENTS
581*

TOTAL
BURDEN
HOURS
WITHOUT
AMENDMENTS
5115
AVERAGE
BURDEN
HOURS
PER
RESPONDENT*
8.8*

AVERAGE
TOTAL
COST
PER
BURDEN
HOUR
$
32.46
*
Amendment
respondents
are
assumed
to
have
only
1/
3
of
the
burden
imposed
as
Full
respondents,
since
the
process
of
amending
is
not
as
extensive
as
it
is
for
a
new
application
for
a
CA.
Current
Subpart
O
language
does
not
address
amendments
/
changes
to
CAs,
which
are
covered
under
Part
31,
so
neither
the
number
of
recipients,
nor
the
respective
burden
hours,
are
included
in
this
calculation.

If
any
burdens
were
found
to
be
imposed
in
the
ICR
by
a
rule
that
supercedes
Subpart
O,
those
burdens,
or
a
percentage
of
those
burdens,
were
removed
from
the
overall
burden
calculation
for
Subpart
O
(
See
Table
1).
The
average
yearly
number
of
respondents
was
7
calculated
using
the
CERCLIS3
and
IFMS
databases.
The
answers
provided
by
a
nation­
wide
Consolidated
funding
survey
of
EPA
regions
was
also
used
to
assist
in
the
estimation
of
imposed
burden.
The
total
number
of
respondents
has
increased
since
the
last
ICR
was
issued,
as
has
the
overall
burden
imposed.
The
extensive
discussion
of
the
requirements
of
this
rule
with
EPA
regional
staff,
the
process
used
in
meeting
those
requirements,
and
the
evolution
of
those
processes,
resulted
in
a
slightly
higher
burden
estimate
than
was
estimated
in
the
prior
ICR.

6(
b):
Estimating
the
respondent
burden
­
The
unit
burden
(
hours)
imposed
upon
States,
Indian
tribes,
and
Political
subdivisions
was
determined
by
gathering
the
burden
estimates
for
all
tasks
associated
with
each
activity
type.
This
data
was
provided
through
interviews
and
meetings
with
EPA
Regional
staff
members
and
State
environmental
agency
staff
who
work
extensively
with
Superfund
Cooperative
agreements
and
Superfund
State
contracts.
The
estimated
burden
for
each
task
was
averaged
and
the
activity
burden
was
calculated
by
aggregating
the
average
burden
for
each
task
within
the
activity,
minus
any
tasks
or
burden
covered
under
other
ICR's.

In
estimating
the
unit
labor
cost,
a
weighted
hourly
rate
is
used.
This
wage
rate
reflects
the
assumptions
that
the
total
number
of
hours
that
are
necessary
for
each
activity
are
divided
across
three
labor
categories.
20
percent
of
the
total
hours
for
each
activity
are
allocated
to
managerial
and
professional
staff
for
their
direction,
professional
input,
and
review
of
activities.
70
percent
of
the
hours
are
allocated
to
technical
staff
for
conducting
a
technical
analysis
and
activities.
10
percent
of
the
total
hours
are
allocated
to
the
support
staff
for
their
preparation
of
documents.

For
all
activities
covered
by
this
ICR,
wage
rates
for
State,
Tribal,
and
Political
subdivision
personnel
are
estimated
to
be
comparable
to
those
of
Federal
government
personnel.
These
wage
rates
were
estimated
based
upon
corresponding
Federal
GS
wage
rates
as
of
January
2001.
The
rates,
as
outlined
below,
also
include
fringe
benefits
estimated
to
be
60%
of
direct
salary.

Management
GS
13,
step
1
$
43.96/
hour
Technical
GS
11,
step
1
$
30.84/
hour
Clerical
GS
7,
step
1
$
20.84/
hour
Based
upon
the
above,
the
weighted
average
[(
43.96*
0.2)+(
30.84*
0.7)+(
20.84*
0.1)]
is
$
32.46/
hour.

The
estimated
burden
associated
with
Pre­
remedial
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
the
Pre­
remedial
Cooperative
Agreement.
EPA
estimates
that
approximately
33
Pre­
remedial
Cooperative
Agreements
involving
states,
tribes,
or
Political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
6.8
hours
are
necessary
to
prepare
all
the
plans,
compliance
documents,
lists
and
schedules
required
in
the
application
for
this
type
of
cooperative
agreement
within
Subpart
O.
8
The
estimated
burden
associated
with
Remedial
Response
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
preparation,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Remedial
response
Cooperative
Agreement.
EPA
estimates
that
approximately
30
Remedial
response
Cooperative
Agreements,
which
involve
states,
Tribes,
and
Political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
10.84
hours
are
necessary
to
prepare
all
the
materials
required
in
an
application
for
this
type
of
cooperative
agreements.
Those
materials
include:
a
project
narrative,
which
includes
much
more
site­
specific
information
than
a
project
narrative
for
a
Pre­
remedial
CA;
compliance
documents
and
certifications;
CERCLA
assurances;
and
notifications.
The
majority
of
the
burden
under
this
CA
is
associated
with
the
preparation
of
the
schedule
of
deliverables.
Though
the
format
of
that
schedule
is
fairly
standard,
the
planning
and
negotiation
involved
can
be
time
consuming.
This
estimate
is
based
on
a
consensus
of
EPA
regional
staff
who
deal
almost
exclusively
with
cooperative
agreements.

The
estimated
burden
associated
with
Enforcement
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
and
certification
documentation
preparation,
such
as
the
quality
assurance
plan,
data
collection,
and
analysis
in
the
preparation
of
materials
involved
in
acquiring
and
operating
within
an
Enforcement
Cooperative
Agreement.
EPA
estimates
that
an
average
of
1
Enforcement
Cooperative
Agreement
will
be
in
place
each
year.
The
Superfund
grants
program
workgroup
estimates
that
43.36
hours
are
needed
to
fulfill
the
requirements
imposed
by
this
type
of
cooperative
agreement.
Those
requirements
include:
creating
the
site
description;
creating
the
site
specific
statement
of
work;
producing
the
statement
designating
lead
site
project
manager;
creating
the
site
specific
health
and
safety
plan;
producing
the
quality
assurance
plan;
developing
the
schedule
of
deliverables;
and
producing
a
copy
of
the
applicable
state,
local,
or
tribal
statutes.
The
majority
of
the
burden
is
imposed
by
the
creation
of
the
site
specific
statement
of
work,
the
quality
assurance
plan,
and
the
schedule
of
deliverables.

The
estimated
burden
associated
with
Removal
Response
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
plan
preparation,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Removal
Response
Cooperative
Agreement.
EPA
estimates
that
approximately
21
Removal
Response
Cooperative
Agreements,
which
involve
states,
Tribes,
and
Political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
42.36
hours
are
necessary
to
prepare
all
the
materials
required
for
this
type
of
cooperative
agreement.
Those
required
materials
include:
a
site
description;
a
site
specific
statement
of
work;
a
statement
designating
lead
site
project
manager;
a
site
specific
community
relations
plan;
a
site
specific
health
and
safety
plan;
a
quality
assurance
plan;
a
schedule
of
deliverables.
Program
experience
has
shown
that
the
majority
of
the
burden
imposed
under
the
requirements
for
this
type
of
cooperative
agreement
can
be
attributed
to
the
schedule
of
deliverables
and
the
quality
assurance
plan.

The
estimated
burden
associated
with
Core
Program
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Core
Program
Cooperative
Agreement.
EPA
estimates
that
22
Core
9
Program
Cooperative
Agreements,
which
involve
states,
Tribes,
and
Political
subdivisions,
will
be
in
place
each
year.
Superfund
program
experience
indicates
that
8
hours
are
needed
to
fulfill
the
requirements
imposed
by
this
type
of
cooperative
agreement.
Those
requirements
include
a
statement
of
work,
and
a
background
statement.
Those
two
requirements
are
responsible
for
the
burden
attributed
to
Core
Program
Cooperative
Agreements.

The
estimated
burden
associated
with
Support
Agency
Cooperative
Agreements
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
and
negotiation
in
preparing
the
materials
required
for
a
Support
Agency
Cooperative
Agreement.
EPA
estimates
that
approximately
45
Support
Agency
Cooperative
Agreements,
which
involve
states,
Tribes,
and
Political
subdivisions,
will
be
in
place
each
year.
EPA
estimates
that
an
average
of
8
hours
are
needed
to
prepare
all
the
materials
required
for
this
type
of
cooperative
agreement.
The
burden
imposed
by
a
Support
Agency
Cooperative
Agreement
can
attributed
to
the
required
statement
of
work.

The
estimated
burden
associated
with
the
Project
Records
requirements
represents
the
number
of
hours
that
are
spent
each
year
beyond
the
10
year
(
Superfund)
retention
requirement
for
record
maintenance,
storage,
and
any
document
requests
that
would
be
made
throughout
the
year.
All
cooperative
agreements
must
meet
these
Project
Records
requirements,
and
incur
the
resulting
burden.
EPA
estimates
that
approximately
152
cooperative
agreements
will
be
in
place
each
year.
Superfund
program
experience
indicates
that
an
average
of
5.6
hours
will
be
required
each
year
to
meet
the
burden
imposed
by
Subpart
O's
Project
Records
requirements.

The
estimated
burden
associated
with
the
Contents
of
an
SSC
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
the
SSC
each
year.
EPA
estimates
that
approximately
52
SSCs
are
in
place
each
year.
The
Superfund
grants
program
workgroup
estimates
that
20
hours
are
needed
to
meet
the
burden
imposed
by
the
requirements
under
an
SSC.
Those
requirements
include:
General
Authorities;
Purpose
statement;
site
description;
statement
to
follow
guidance;
statement
of
work;
schedule
of
deliverables;
SPOC;
CERCLA
assurances;
list
of
Support
agency
Cooperative
Agreements;
sanctions
for
failure
to
comply
with
the
terms
of
the
SSC;
site
access;
joint
inspection
of
the
remedy;
exclusion
of
third
party
benefits;
State
review;
and
a
list
of
responsible
party
activities.

The
estimated
burden
associated
with
Consolidated
Funding
represents
the
number
of
hours
that
are
spent
in
research,
data
collection,
analysis,
negotiation,
and
preparation
of
Consolidated
Funding
agreements
each
year.
EPA
estimates
that
approximately
2
Consolidated
Funding
agreements
are
in
place
each
year.
EPA
estimates
that
approximately
68
hours
a
year
are
necessary
to
meet
the
requirements
of
a
Consolidated
Funding
agreement.
The
majority
of
the
burden
complying
with
the
requirements
of
this
type
of
agreement
are
due
to
the
fact
that
to
initiate
one
Consolidated
Funding
Cooperative
Agreement
imposes
about
the
same
burden
as
three
regular
cooperative
agreements.
The
amendment
process,
however,
is
much
less
costly
and
the
number
of
amendments
for
Consolidated
Funding
Cooperative
Agreements
are
far
fewer
than
for
a
regular
cooperative
agreement.
Amendment
costs
are
tracked
under
Part
31.
10
6(
c).
Estimating
Agency
Burden
and
Costs
­
A
"
unit"
burden
is
the
burden
incurred
by
a
respondent
for
performing
a
Cooperative
Agreement
(
CA)
specific
activity.
The
Federal
Government
incurs
a
burden
under
an
estimated
581
Cooperative
Agreement
and
Superfund
State
Contract
(
SSC)
activities
per
year
for
reporting,
certifications,
schedules,
notifications,
assurances,
and
record
keeping
activities.
The
unit
burden
(
hours)
imposed
upon
the
Federal
government
was
determined
by
gathering
the
burden
estimates
for
all
tasks
associated
with
each
activity
type.
This
data
was
provided
through
interviews
and
meetings
with
EPA
Regional
and
Headquarters
staff
members
who
work
extensively
with
Superfund
Cooperative
agreements
and
Superfund
State
contracts.
The
estimated
burden
for
each
task
was
averaged
and
the
activity
burden
was
calculated
by
aggregating
the
average
burden
for
each
task
within
the
activity,
minus
any
tasks
or
burden
covered
under
other
ICR's.

In
estimating
the
unit
labor
cost,
a
weighted
hourly
rate
is
used.
This
wage
rate
reflects
the
assumptions
that
the
total
number
of
hours
that
are
necessary
for
each
activity
are
divided
across
three
labor
categories.
20
percent
of
the
total
hours
for
each
activity
are
allocated
to
managerial
and
professional
staff
for
their
direction,
professional
input,
and
review
of
activities.
70
percent
of
the
hours
are
allocated
to
technical
staff
for
conducting
a
technical
analysis
and
activities.
10
percent
of
the
total
hours
are
allocated
to
the
support
staff
for
their
preparation
of
documents.

For
all
activities
covered
by
this
ICR,
wage
rates
were
estimated
based
upon
the
Federal
GS
wage
rates
as
of
January
2001.
The
rates,
as
outlined
below,
also
include
fringe
benefits
estimated
to
be
60%
of
direct
salary.

Management
GS
13,
step
1
$
43.96/
hour
Technical
GS
11,
step
1
$
30.84/
hour
Clerical
GS
7,
step
1
$
20.84/
hour
Based
upon
the
above,
the
weighted
average
[(
43.96*
0.2)+(
30.84*
0.7)+(
20.84*
0.1)]
is
$
32.46/
hour.

The
estimated
burden
is
incurred
by
activities
under
the
following
types
of
CAs/
SSCs
and
other
requirements:

°
Pre­
remedial
Cooperative
Agreements;
°
Remedial
Response
Cooperative
Agreements;
°
Enforcement
Cooperative
Agreements;
°
Removal
Cooperative
Agreements;
°
Core
Program
Cooperative
Agreements;
°
Support
Agency
Cooperative
Agreements;
°
Records
Retention;
°
Superfund
State
Contract;
°
Conclusion
of
the
SSC
°
Consolidated
Funding.
11
The
estimated
average
burden
associated
with
each
CA/
SSC/
Other
requirement
is
discussed
below
and
summarized
in
Table
3,
below.

Table
3
­
Federal
Burden
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
number
of
respondents
per
Year
(
Full)
Average
number
of
potential
respondents*
(
Amendments)
Total
Burden
(
Hours)
Total
Cost
(
Dollars)

Pre­
remedial
CA
23
$
32.46
$
746.58
33
26
958.3
$
31,107.39
Remedial
response
CA
36.4
$
32.46
$
1,181.54
30
19
1322.53
$
42,929.32
Enforcement
CA
35
$
32.46
$
1,136.10
1
0
35
$
1,136.10
Removal
response
CA
36
$
32.46
$
1,168.56
21
1
768
$
24,929.28
Core
program
CA
15
$
32.46
$
486.90
22
22
440
$
14,282.40
Support
agency
CA
14
$
32.46
$
454.44
45
36
798
$
25,903.08
Records
retention
2
$
32.46
$
64.92
375
0
750
$
24,345.00
SSC
40
$
32.46
$
1,298.40
52
0
2080
$
67,516.80
Conclusion
of
SSC
13
$
32.46
$
421.98
0
0
0
$
0
Consolidated
funding
$
32.46
2
3
TOTAL
581
107*
7151.83*
$
232,149.37
TOTAL
NUMBER
OF
RESPONDENTS
581*

AVERAGE
BURDEN
HOURS
PER
RESPONDENT*
12.31*

AVERAGE
TOTAL
COST
PER
BURDEN
HOUR
$
32.46
*
Amendment
respondents
are
assumed
to
have
only
1/
3
of
the
burden
imposed
as
Full
respondents,
since
the
process
of
amending
is
not
as
extensive
as
it
is
for
a
new
application
for
a
CA.
Current
Subpart
O
language
does
not
address
amendments
/
changes
to
CAs,
12
which
are
covered
under
Part
31,
so
neither
the
number
of
recipients,
nor
the
respective
burden
hours,
are
included
in
this
calculation.

As
shown
in
Table
3,
the
total
number
of
hours
and
the
cost
to
EPA
are
summarized
below.

Federal
Hours/
Respondent
x
#
of
Respondents
­
12.31
hours
x
581
respondents
=
7152
hours
Federal
Cost/
Respondent
x
#
of
Respondents
­
$
399.57
x
581
respondents
=
$
232,150
6(
d):
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
­
EPA
estimates
that
an
average
of
581
respondents
per
year
will
enter
into
cooperative
agreements
annually
to
lead
Superfund
cleanups
and
107
respondents
will
amend
these
cooperative
annually
during
the
period
covered
by
this
ICR.
The
burden
imposed
by
amendments
to
cooperative
agreements
is
covered
under
40
CFR
Part
31.
Table
2
details
these
costs
by
activity.

The
burden
imposed
on
respondents
is
shown
in
Table
2,
and
summarized
below.

State
Hours/
Respondent
x
#
of
Respondents
­
8.8
hours
x
581
respondents
=
5,115
hours
State
Cost/
Respondent
x
#
of
Respondents
­
$
303.21
x
581
respondents
=
$
176,163
6(
e).
Bottom­
line
Burden
Hours
and
Cost
Tables
­
The
unit
burden
(
hours)
imposed
upon
the
Federal
government
and
respondents
was
determined
by
gathering
the
burden
estimates
for
all
tasks
associated
with
each
activity
type.
This
data
was
provided
through
interviews
and
meetings
with
EPA
Regional
and
Headquarters
staff
members
who
work
extensively
with
Superfund
Cooperative
agreements
and
Superfund
State
contracts.
The
estimated
burden
for
each
task
was
averaged
and
the
activity
burden
was
calculated
by
aggregating
the
average
burden
for
each
task
within
the
activity,
minus
any
tasks
or
burden
covered
under
other
ICR's.

TOTAL
ESTIMATED
RESPONDENT
(
STATE)
BURDEN
AND
COST
SUMMARY
State
Hours/
Respondent
x
#
of
Respondents
­
8.8
hours
x
581
respondents
=
5,115
hours
State
Cost/
Respondent
x
#
of
Respondents
­
$
303.21
x
581
respondents
=
$
176,163
TOTAL
ESTIMATED
AGENCY
BURDEN
AND
COST
SUMMARY
Federal
Hours/
Respondent
x
#
of
Respondents
­
12.31
hours
x
581
respondents
=
7152
hours
Federal
Cost/
Respondent
x
#
of
Respondents
­
$
399.57
x
581
respondents
=
$
232,149
6(
e).
Reason
for
changes
­
EPA
regional
staff
members
and
state
environmental
agency
staff
with
extensive
experience
in
managing
and
supervising
Superfund
cooperative
agreements
were
consulted
in
detail
during
the
process
of
producing
this
information
collection.
These
13
consultations
consisted
of
several
conference
calls
where
potential
and
actual
burdens
imposed
on
states
and
political
subdivisions
by
the
Superfund
rule
were
discussed.
The
experience
of
the
staff
involved
provides
for
more
accuracy
in
the
burden
calculation.

This
data
is
requested
to
comply
with
the
provisions
mandated
by:
Statute
or
regulations
(
40
CFR
Part
30
AND
31);
OMB
Circulars;
or
added
by
EPA
to
ensure
sound
and
effective
assistance
management.
Accurate,
complete
data
is
required
to
obtain
funding,
while
no
pledge
of
confidentiality
is
provided.

6(
g):
Burden
Statement
The
average
calculated
burden
imposed
by
the
Superfund
rule
upon
States
and
Political
subdivisions
is
8.8
hours
per
respondent,
at
an
average
cost
of
$
303.21
per
respondent
and
a
total
of
5,112
hours,
and
a
total
cost
of
$
176,163.
The
average
calculated
burden
imposed
by
the
Superfund
rule
upon
the
Federal
Government
is
12.31
hours
per
respondent
for
a
total
of
7152
hours,
at
an
average
cost
of
$
399.57
per
respondent
and
a
total
cost
of
$
232,149.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
